IR 05000155/1980016
| ML19351F231 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/01/1980 |
| From: | Fisher W, Hueter L, Lovendale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19351F229 | List: |
| References | |
| 50-155-80-16, NUDOCS 8101120018 | |
| Preceding documents: |
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| Download: ML19351F231 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No.
50-155/80-16 Docket No.
50-155 License No.
DPR-6 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant Inspection At: Big Rock Point Site, Charlevoix, MI Inspection Conducted: November 3-6, 1980 (l'Cicc:$tlt Inspectors:
P. C. Lovendale
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Lv3. Hueter
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r Approved By:
W. L. Fisher, hief
/.2_ // /& c Fuel Facility Projects and Radiation Support Section Inspection Summary:
Inspection on November 3-6, 1980 (Report No. 50-155/80-16)
Areas Inspected: Routine, unannounced inspection of refueling radiation protection activities, including: procedures, advanced planning and pre-paration, training, exposure control, posting and control, material control, and surveys.
It also included licensee actions taken in response to the Health Physics Appraisal, IE Bulletin 80-10, and various other IE information notices and circulars. The inspection involved 54 inspector-hours onsite by two NRC inspectors.
Results: Of the ten areas inspected, no items of noncompliance were identified in nine areas; one item of noncompliance was identified in one area (Infraction - failure to post radiation areas - Paragraph 9.a).
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1.
Persons Contacted
- C. J. Hartman, Plant Superintendent
- R. B. DeWitt, Vice President, Nuclear Operations (CPCo)
- G.
Fox, Chemistry and Radiation Protection Supervisor
- M.
Dickson, General Health Physicist R. Burdette, Senior Chemistry and Radiation Protection Technician R. Doan, Training Coordinator S. VanderHeide, Senior Chemistry and Radiation Protection Technician
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J. Warner, Chemistry and Radiation Protection Clerk / Secretary
- Denotes those attending the exit interview.
In addition, Mr. G. C. Wright from NRC Region III attended the exit interview.
2.
Gene ra l This inspection, which began with a plant tour and visual observation of facilities and equipment, posting, labeling, and access controls at 3:00 p.m. on November 3, 1980, was conducted to examine routine aspects of the radiation protection program during refueling operations.
During this and subsequent tours, the inspector used an NRC survey instrument to monitor selected areas throughout the plant. Two improperly posted radiation areas were noted (Paragraph 9.a).
The inspectors noted that housekeeping was good except for a few step-off areas which were cluttered with used protective clothing.
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3.
Licensee Action On Previous Inspection Findings
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(0 pen) Noncompliance (50-155/80-04): concerning failure to control
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access to high radiation areas. Work requests have been submitted to install fencing and locked doors at entrances to these areas.
(0 pen) Noncompliance (50-155/80-04): concerning offshift radiation protection coverage. An individual has been hired to train RWP-exempt personnel in all six criteria for individuals qualified in radiation protection procedures contained in D. L. Ziemann's letter of March 15, 1977, to Consumers Power Company.
4.
Organization TwoC&RPtechnicianshavebeenhiyydandoneprofessionalposition filled since the last inspection.-
Technician staffing is now at full complement.
The new professional position within the C&RP Department was created
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and filled as a result of weaknesses identified by the Health Physics Appraisal Team iu March 1980. This person is responsible for upgrading the radiation protection training of the plant staff (to be implemented by January 1, 1981), which includes: training RWP-exempt personnel, 1/
IE Inspection Report 50-155/80-04.
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training the shift technical advisors in radiation evaluations and offsite dose consequences under abnormal conditions, and training of C&RP technicians. Also, this person is responsible for implementing and maintaining an ALARA program.
The inspectors reviewed this individual's qualifications and found that he holds an Associate Degree and has attended several CPCo sponsored short courses. For several years he was assigned to the company's corporate office, where he worked on special projects
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related to health physics. He appears to have limited academic training and experience in health physics at the plant level.
In view of the broad responsibilities involving technical expertise and the implicit need for relevant experience, the inspectors have reservations regarding the ascigned individual's present ability to meet the commitment.
This matter will be reviewed during future inspections.
No items of noncompliance were identified.
5.
Radiation Protection Procedures Outage radiation protection work generally is conducted under normal radiation protection procedures. The health physicist participates in outage planning and reviews work procedures written by other groups.
The inspectors found the following procedures to be consistent with regulatory requirements and good health physics practices.
a.
RP-27 Rev. 3 5/30/80 Issuing and Recording RWPs b.
RP-29 Rev. 11 9/12/80 Radiologic.1 Surveys c.
RP-31 Rev. 7 10/20/80 Personal Dosimetry d.
NOD-14 Rev. 0 7/23/80 Health Physics Policy No items of noncompliance or deviations were identified.
6.
Advance Planning and Preparation Planning and preparatica for this outage has provided an adequate supply of equipment and personnel to insure that the radiation protection program is fully implemented.
The plant health physics staff has been augmented with four contracted health physics technicians, all of whom meet or exceed the requirements of ANSI N18.1-1971.
The inspectors noted an adequate supply of anticontamination clothing, respiratory equipment, and portable survey instruments.
No items of noncompliance or deviations were identified.
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7.
Training The inspectors reviewed training records for selected individuals to confirm that training consistent with 10 CFR 19.12 had been given. No problems were noted.
The Health Physics Appraisal indicated several problems and weaknesses in the RWP-exempt, C&RP technician, maintenance, and visitor training prog rams. The licensee's response to these findings, dated July 18,
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1980, stated that an additional C&RP professional would be hired to upgrade these programs.
This individual has been hired and progress is being made, but the inspectors doubt whether this individual can complete his assigned tasks in the alloted time (Paragraph 4).
No items of noncompliance or deviations were identified.
8.
Exposure Control a.
External Exposure Exposure records from March 1980 to date were reviewed, including forms NRC-4, pocket dosimeter totals, and TLD results. No problems were noted.
b.
Internal Exposure The inspectors reviewed records of respirator training, MPC-hour accumulation, bioassay, and air sampling. No body burdens indicative of an exposure greater than the 40 MPC-hour control measure were noted.
c.
ALARA In March 1980, the Health Physics appraisal team found that the
"as low as reasonably achievable" (ALARA) program requires significant improvement, especially in the area of program formalization and Chemistry and Radiation Protection staff authority.
In response to the above, on July 23, 1980, the Nuclear Operations Department issued Revision 0 of Policy No.
N0D-014 titled " Health Physics Policy," a thirteen page policy to be followed uniformly throughout Consumers Power Company.
Regarding staff authority, the policy states "The Facility Radiation Protection Manager and members of the Radiation Protection Department shall have the authority to enforce all Health Physics Procedures and to stop work on any task which he feels could cause an undue risk to the health and safety of the worker or the public. Until such time as conditions can be evaluated and corrections made by those individuals responsible for the task, work will not be continued."
The Health Physics Policy also addresses a commitment to ALARA, as noted in the following excerpts: "All Radiation Workers,
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within the assigned scope of their duties, are responsible for maintaining their own and their subordinates' radiation exposure as low as reasonably achievable and for following the requirements of the facility. programs and procedures implementing this policy.
Consumers Power Company is committed to maintaining radiation exposures to employees "as low as reasonably achievable" (ALARA), as required in 10 CFR 20.1(c).
To meet this commitment, each user facility shall develop and maintain an ALARA program consistent with the ALARA guidance developed by the General
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Office Health Physics Section."
l In addition, a first draft of the General Office Health Physics Section Guidance, in circulation at the time of this inspection, was reviewed. The draft section on implementation of ALARA provides for an ALARA check list to be reviewed and completed for jobs which have an anticipated man-rem total over a set number of man-rem and for design projects having an impact on exposure of personnel.
It recommends: 1) an informal ALARA review on jobs having an anticipated man-rem less than required for the ALARA check list and 2) an estimate of the man-rem be documented before a job and a followup review performed following task completion. As noted before (Paragraph 4), the individual filling the new professional position in the C&RP Department is responsible for implementing and maintaining an ALARA progcam
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at the facility. This individual was assigned to this position only two to three weeks before the inspection, just before the refueling outage began. No specific ALARA goals in terms of man-rems have been established for specific jobs or for the outage as a whole.
Previous refueling outages have resulted in expenditure of 250-300 man-rems, according to licensee personnel.
Several pre-outage meetings were held by the plant Health Physicist with both regular and contracted health physics technicians regarding outage work and maintaining exposures as low as reasonably achievable. The licensee is attempting for the first time to control yearly total exposure of each employees, as well as quarterly exposure. A new supply of lead blankets was ordered for localized shielding of hot spots and piping.
New instruments purchased include two Rad Guns, two Eberline digital readout RO II's, a Xetex Model 302B extendible probe
high range survey meter, and two Super DAD's designed to alarm at a preset dose. The latter instruments are intended to reduce health physics techneian exposures when covering jobs in high radiation fields. ALARA efforts associated with In-Service Inspection and modification of reactor vessel water level-indicators, which involve general fields in work areas from 200 to 1800 mR/hr in the Recire Pump Room and the Steam Drum, included:
(1) review of procedures, (2) discussion / training of workers and supervisors of the activity, (3) use of a " spider type" mechanical hoist on scaffolding to reduce time in the area, and (4) posting of hot spots on pipes to identify those areas to avoid when feasible.
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The individual assigned ALARA responsibilities plans to utilize the existing Post Monitoring Evaluation (RP-33) system for health physics technicians to identify ALARA concerns. He also plans to review new and revised procedures with regard to ALARA considerations.
No items of noncompliance or deviations were identified.
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Posting and Control a.
Posting During facility tours, the inspectors examined the posting of contaminated areas, radiation areas, and high radiation areas.
Several inconsistencies were noted. The fuel pool filter area was posted in two different places.
Both signs indicated the area was surveyed on October 24, 1980, but contained conflicting information as to the radiation levels in the area. The fuel pool heat exchanger room was posted as a radiation area with a maximum of 900 mR/hr at the Y-strainer; the recirculation pump seal water sink was posted as a radiation area with 350 mR/hr maximum at the sink. The inspectors found that these maximum readings were " hot spots" and not " general area" readings. The licensee should be more precise when posting radiation area
" hot spots" and review area postings to eliminate conflicting information.
The fuel pool filter area was posted as a high radiation area and was chain locked. Control of this area was the subject of an item of noncompliarae in IE Inspection Report 50-155/80-04.
The licensee's response to that item of noncompliance stated that the area would be provided with a locked door if procedural controls failed to keep the area from becoming a high radiation area.
Since this area continues to be a high radiation area, the licensee has taken steps to install a fence and locked door at the entrance. Control of this area will be reviewed during a future inspection.
During a tour of the turbine building, the inspectors surveyed room 125, which contained a small roped off and posted radiation area used to store drums of radwaste filters. The radiation levels at the ropes approached 100 mR/hr. The radiation levels in the surrounding room were greater than 5 mR/hr. This room was not posted as a radiation area. The inspectors noted that problems associated with the posting of this area had been brought to the licensee's attention by the Health Physics Appraisal Team in March 1980.
Another area surveyed was room 121, which was found to exceed 5 mR/hr. The inspectors found no signs indicating that this was a radiation area.
Further investigation showed that the room was posted, but that the~ sign was not visible. The sign was being used as a coat rack.
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Failure to conspicuously post rooms 125 and 121 as radiation areas is apparent noncompliance with 10 CFR 20.203(b).
b.
Control Access control remains as previously stated. ! Action has been taken to install fencing and locked doors on high radiation areas which are presently chain locked.
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During the course of the inspection, it was noted that many people leaving the control area were found to have low-level contamination on their shoes. The inspectors noted that no protective measures, such as wearing shoe covers or establishing step-off areas, were instituted while the source of contamination was investigated (about two days). This practice allowed for the possible spread of contamination from the sphere through the turbine building and out to access control. This matter was discussed with the licensee during the exit interview.
No items of noncompliance were identified.
10.
Surveys
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The inspectors reviewed refueling outage air sample data for the period October 29 through November 5, 1980. About a dozen air samples were collected and analyzed daily, including routine samples at various locations and special job related samples.
Charcoal filters showed no detectable iodine-131 activity, including the samples taken during and immediately following reactor head removal.
Occasional particulate samples showed concentrations above the MPC of 3E-9 uCi/ml used for gross beta activity.
In such cases, gamma isotopic analyses were performed showing the airborne concentration to be less than one MPC in all cases (maximum being 0.82 MPC).
Routine direct radiation and contamination survey data for the period October 29 through November 5, 1980, were reviewed.
The three CAM's and the eight frisking stations are checked for proper
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operation and normal response. Maintenance orders appear to be initiated promptly when equipment problems are noted. Many smears are taken during the surveys. Only minor contamination was noted.
As an example, of the 63 smears in the containment sphere on
November 5,onlythreeshowedactivitygreaterthan1000dpm/100cm withthemaximumbeing3100dpm/100cm. About 20 smears showed
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levels of 400 dpm/100cm or greater; decontamination efforts were applied to these areas. Refer to Paragraph 9.b regarding low-level contamination problems observed during the inspection.
No items of noncompliance or deviations were identified.
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IE Circular No. 79-15 This circular concerned malfunctions of SurvivAir Mark I SCBAs. The licensee stated that the station does not own or use any SurvivAir equipment. Therefore no action was taken.
12.
IE Bulletin No. 80-10 The above bulletin titled " Contamination of Nonradioactive System
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and Resulting Potential for Unmonitored, Uncontrolled Release of Radio-activity to Environment," issued May 6, 1980, described a possibly generic problem and instructed recipients of the bulletin to take action as appropriate for four items.
First, to review the facility design and operation to identify systems that are considered nonradioac-tive (or described as nonradioactive in the FSAR), but that could become radioactive through interfaces with radioactive systems.
Second, to establish a routine sampling / analysis or monitoring program for these systems in order to identify promptly any contaminating events which could lead to unmonitored, uncontrolled liquid or gaseous releases to the environment.
Instructions for items three and four were conditional, identifying applicable restrictions if nonradioactive systems become contaminated.
Actions taken in response to Items 1 and 2 were to be completed in 45 days from the date of the bulletin. The specifics were to be documented and made available to the NRC for review during future inspections.
A verification letter documenting completion of the required actions was to be submitted within 60 days from the date of the bulletin. A verification letter dated July 11, 1980, to the Director of NRC Region III office stated that the required actions had been taken and that documentation of such action was available for review during future inspections.
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The documentation package prepared by the licensee in response to the subject bulletin was reviewed and found to be insufficient. The documentation notes that this bulletin is similar to IE Circular No. 77-14, dated November 28,_1977, entitled, " Separation of Contaminated Water Systems from Non-Contaminated Plant Systems."
In response to Item 1 (identifying nonradioactive systems with
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potential for contamination) of IE Bulletin No. 80-10, the licensee's documentation indicates that all "special consideration" items listed had been reviewed in response to IE Circular 77-14, and that this presr.nt review of these systems indicates that the requirements of item '. have been completed. However, the inspectors note that the response apparently does not address the plant air system used for breathing purposes.
Nor, apparently, does the response address the equipment and floor drain system or the yard drain system. The latter has a potential interface with contamination when filling and dewatering spent resin casks.
In response to item 2 (establishment of routine sampling / analysis or monitoring program) of IE Bulletin No. 80-10, the licensee's documentation-8-
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refers to Event Report BRP-78-55, dated August 1978, concerning violation of 10 CFR 20.301 (Contaminated Demineralized Water) and the subsequent establishment of routine sampling / analysis of the de-mineralized water system at six different locations monthly.
In addition, the response to IE Circular No. 77-14 indicated that both service water and emergency condenser vent are monitored. It does not address sampling / analysis or monitoring for the plant air system, yard drains, potable water, heating boiler system, and other systems that may interface with a contaminated system. The licensee needs
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to provide further information to assess the response to this Bulletin.
13.
IE Information Notice No. 80-22 This information notice concerned breakdowns in contamination control programs and, in particular, releases of radioactive material to unrestricted areas via disposal of material in local landfills and scrap material sales to salvage dealers. The inspectors reviewed the licensee' procedures for surveying and releasing material from the plant site and determined that adequate controls were used to prevent these unauthorized releases. No problems were identified.
14.
IE Circular No. 80-14 This circular concerns contamination of plant demineralized water system and resultant internal contamination of personnel. The licensee has found contamination in their demineralized water system in the past and has labled all water taps prohibiting human consumption.
Also, a sampling program is in effect to monitor this system. No problems were noted.
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15.
Independent Measurements The inspectors made independent measurements, using an NRC instrument, of radiation levels in several areas throughout the facility and compared the results with the licensee's instrument.
Included was a comparison of readings using the licensee's calibration facility.
Agreement was within plus or minus ten percent. No problems were noted.
16.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
on November 6, 1980. The following items were discussed:
a.
The purpose and scope of the inspection, b.
The item of noncompliance (Paragraph 9.a).
c.
Discrepancies found in the IE Bulletin 80-10 documentation (Paragraph 12). The licensee agreed to provide additional information.
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Contamination control and lack of protective measures (Paragraph 9.b).
The licensee agreed that protective measures should have been taken.
Inconsistencies noted in radiation area postings (Paragraph 9.a).
e.
f.
Inspectors' concerns regarding selection of C&RP professional (Paragraph 4).
(This item was discussed in a separate meeting
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with the Plant Superintendent before the exit interview.)
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